Terms & Conditions

Effective Date: April 2026
Last Updated: December 2025

Acceptance of Terms

By using Raffy you agree to these Terms. Please read them carefully. They protect you, your child, and us. If you do not agree, do not use the App.

1.What Raffy Is (and Isn't)

1.1 WHAT RAFFY PROVIDES

Raffy is an information and tracking tool designed to help families managing food allergy desensitisation treatment. It helps you:

• Track your child's doses, timing, and reactions

• Log cofactors and post-dose observations

• Identify patterns over time

• Access general educational information about OIT and food allergy

• Generate organised records to share with your supervising allergist

1.2 WHAT RAFFY IS NOT

Raffy is not: a medical service or healthcare provider · a source of medical advice, diagnosis, or treatment · a substitute for professional medical care · a medical device regulated by the TGA · an emergency response system · intended to diagnose, treat, cure, or prevent any disease or condition.

1.3 ASCIA ALIGNMENT

Raffy is designed to support families following the ASCIA Graduated Exposure protocol and similar clinician-directed OIT programs. Raffy does not set, recommend, or override any dose or protocol decision: those remain exclusively your allergist's responsibility.

2. Medical Disclaimer — Critical

2.1 NO MEDICAL ADVICE

Raffy does not provide medical advice. All content in Raffy is for general educational and tracking purposes only. It is not personalised medical advice for your child, a recommendation for any specific treatment, or a replacement for professional medical judgment.

2.2 ALWAYS CONSULT YOUR HEALTHCARE PROVIDER

Consult a qualified healthcare provider for all medical decisions relating to your child, before starting, stopping, or changing any treatment; for any reaction that concerns you; and when interpreting patterns or data from Raffy. Your allergist's advice always supersedes any information in Raffy.

2.3 NO DOCTOR–PATIENT RELATIONSHIP

Using Raffy does not create a doctor–patient or any other clinical relationship between you and Raffy Pty Ltd, our team, or any affiliated clinicians.

2.4 INDIVIDUAL VARIATION

Every child is unique. General information in the App may not apply to your child's specific circumstances. Your healthcare provider is the appropriate source of individual guidance.

2.5 YOUR RESPONSIBILITY

You are solely responsible for all medical decisions regarding your child's care. By using Raffy, you confirm that you will exercise independent clinical judgment, verify information with healthcare providers before acting, and will not make medical decisions based solely on Raffy.

3. Beta Release Status

Raffy has progressed from Pilot (December 2025) to Beta. The app is more stable and feature-complete than during the Pilot, but it remains under active development. The limitations below still apply.

3.1 WHAT BETA MEANS

During the Beta release:

• The app is functional but continues to receive updates, fixes, and improvements

• Some features may behave unexpectedly or change

• Scheduled and unscheduled maintenance may cause temporary interruptions

• Despite our data safeguards, no system is infallible. Maintain your own independent records

3.2 YOUR INDEPENDENT RECORDS

You must maintain your own independent records of your child's OIT protocol, doses, and reactions. Do not rely solely on Raffy for medical record-keeping. Use the in-app export function regularly 

(Stats → Export PDF).

3.3 FEEDBACK

We welcome feedback through in-app tools, surveys, and email. By providing feedback, you grant us a non-exclusive, royalty-free licence to use that feedback to improve Raffy, without compensation or attribution. This does not affect your ownership of your personal data.

3.4 FUTURE VERSIONS

Features available in Beta may be modified in subsequent releases. Where we make material changes that affect your use of a paid feature, we will give you reasonable notice and the option to cancel without penalty.

4. TGA and Regulatory Status 

Raffy is not a regulated medical device under the Therapeutic Goods Act 1989 (Cth). It is a self-management tracking tool that falls within the excluded software category under the Therapeutic Goods (Medical Devices) Regulations 2002.

4.1 BASIS FOR EXCLUSION

Raffy is designed to help families self-manage an existing condition (food allergy under clinical OIT) by tracking doses and reactions without providing specific treatment recommendations or replacing clinical decision-making. 

Under TGA guidance (updated February 2026), software intended for the self-management of a condition, without providing specific treatment or treatment suggestions, falls within the excluded software category and does not require inclusion in the Australian Register of Therapeutic Goods (ARTG).

4.2 ONGOING OBLIGATION

Our TGA exclusion status is assessed against Raffy's current feature set. If we introduce features that could provide specific treatment recommendations or influence clinical decisions in a manner that no longer meets the exclusion criteria, we will reassess our regulatory status before releasing those features. If you believe any Raffy feature may cross that line, please contact us at raffy@raffyallergy.com.

4.3 OTHER APPLICABLE LAWS

TGA exclusion does not affect our obligations under the Privacy Act 1988 (Cth), the Australian Consumer Law, or any other applicable legislation. Those obligations remain in full force.

5. Eligibility and Account

5.1 WHO MAY USE RAFFY

To create an account and use Raffy, you must:

• Be at least 18 years of age

• Be a parent or legal guardian with authority to consent on behalf of the patient child

• Reside in Australia or be accessing Raffy from Australia

• Agree to these Terms and our Privacy Policy

Raffy is not intended to be directly used by individuals under 16. If you are 16 or 17, you may only use Raffy with verified parental consent. See our Privacy Policy (Section 10) for full children's privacy terms.

5.2 ACCOUNT ACCURACY

You agree to provide accurate, current, and complete information when creating and maintaining your account. You are responsible for keeping account details up to date.

5.3 ACCOUNT SECURITY

You are responsible for maintaining the confidentiality of your password, not sharing account access, and notifying us immediately of any unauthorised access at raffy@raffyallergy.com. You are responsible for all activity under your account.

5.4 ONE ACCOUNT PER FAMILY

Accounts are for personal, household use only. You may add multiple patient profiles within a single family account. Sharing your account with people outside your household is not permitted.

6. Your Responsibilities

6.1 ACCURATE INFORMATION

You agree to enter accurate information into Raffy. Inaccurate data reduces the value of your own records and any clinician export you share.

6.2 APPROPRIATE USE

You agree to use Raffy only for lawful, personal, non-commercial purposes in accordance with these Terms. You must not:

• Use Raffy to harm, harass, or deceive any person

• Attempt to access data belonging to another user

• Reverse engineer, decompile, or tamper with the App or its infrastructure

• Use automated tools to scrape, crawl, or extract data from the App

• Distribute, resell, or commercialise access to Raffy

• Upload content that is unlawful, defamatory, offensive, or infringes third-party rights

6.3 MEDICAL CARE CONTINUES

You confirm that you will maintain your child's existing clinical relationships, continue regular appointments with your supervising allergist, and seek emergency care when appropriate. Raffy does not reduce your medical obligations.

6.4 INDEPENDENT RECORDS

You acknowledge that you must maintain independent records as set out in Section 3.2. Regular data export is available at no additional cost.

7. Subscriptions and Fees 

7.1 FREE AND PAID TIERS

Raffy offers a free trial for 7 days and a paid subscription ("Raffy Core") with features including extended analytics, clinician sharing tools, and priority support. Details of current plans and pricing are available at raffyallergy.com/pricing.

7.2 BETA ACCESS

During the Beta release period (April 2026 – [end date TBC]), all Raffy Core features are available at no charge. We will give you at least 7 days' written notice before any free Beta access period ends and paid subscriptions commence.

7.3 PRICING CHANGES

We may change subscription pricing. We will give you at least 7 days' written notice of any price increase before it takes effect. If you do not accept a price increase, you may cancel your subscription before the new price takes effect and will not be charged at the new rate. This right cannot be waived.

7.4 BILLING AND CANCELLATION

Subscriptions are billed in advance on a monthly, quarterly or annual cycle (your choice). You may cancel at any time through Settings → Subscription or by contacting raffy@raffyallergy.com. Cancellation takes effect at the end of your current billing period; you retain access until then.

7.5 REFUNDS AND AUSTRALIAN CONSUMER LAW

Your rights under the Australian Consumer Law (ACL) are not limited by these Terms. If Raffy fails to meet a consumer guarantee (due care and skill; reasonably fit for purpose), you may be entitled to a remedy: a fix, re-performance, or refund, as set out in Section 9.4. To request a refund, contact raffy@raffyallergy.com.

7.6 NO REFUND FOR CHANGE OF MIND

Except as required by the ACL or as described in Section 7.3 (pricing changes), we do not offer change-of-mind refunds for completed billing periods. Partial-period credits may be offered at our discretion.

8. Intellectual Property

Raffy, including all software, design, content, trade marks, and features, is owned by Raffy Pty Ltd (ACN 695425284) and is protected by Australian and international intellectual property laws.

8.1 LICENCE TO YOU

We grant you a limited, non-exclusive, non-transferable, revocable licence to use the App for personal, non-commercial purposes in accordance with these Terms. This licence ends when your account is terminated.

8.2 YOUR CONTENT

You retain ownership of all data you enter into Raffy (dose logs, notes, reaction records). You grant us a limited licence to store, process, and display your data solely to provide the App to you and as described in the Privacy Policy. We do not claim ownership of your health data.

8.3 RESTRICTIONS

You must not copy, modify, distribute, sublicense, sell, reverse engineer, or create derivative works from Raffy or its content, except as expressly permitted by law (including fair dealing rights under the Copyright Act 1968 (Cth)).

9. Liability and Warranties

9.1 AUSTRALIAN CONSUMER LAW — NON-EXCLUDABLE GUARANTEES

Under the Australian Consumer Law (Competition and Consumer Act 2010 (Cth), Schedule 2), services come with guarantees that cannot be excluded. These include that services will be rendered with due care and skill and will be reasonably fit for the purpose for which they are supplied. Nothing in these Terms excludes or modifies these statutory guarantees or your rights under the ACL.

9.2 WHAT WE CANNOT AND DO NOT EXCLUDE

We do not exclude liability for:

• Death or personal injury caused by our negligence

• Fraud or fraudulent misrepresentation

• Breach of a consumer guarantee under the ACL that cannot be excluded by law

9.3 WHAT WE EXCLUDE (WHERE THE LAW PERMITS) 

To the extent permitted by law, and subject to the ACL guarantees that cannot be excluded, we exclude or limit liability for:

• Medical decisions made by you (with or without information from Raffy)

• Health outcomes related to your child's OIT treatment

• Delays in seeking emergency medical care

• Reliance on general information in Raffy rather than personalised medical advice

• Loss or corruption of data where you have failed to maintain independent records (see Section 3.2)

• Service interruptions, downtime, or Beta-phase instability

• Third-party service failures (e.g., cloud hosting outages)

• Indirect, consequential, or special damages — to the maximum extent permitted by law

9.4 YOUR REMEDY IF WE FAIL A CONSUMER GUARANTEE

If Raffy fails to meet a consumer guarantee under the ACL:

• Major failure (the App is substantially not fit for purpose): you may cancel your subscription and receive a full or partial refund of fees paid, or compensation for any reasonably foreseeable loss.

• Minor failure: we will fix the problem or re-perform the relevant service within a reasonable time at no charge.

9.5 LIABILITY CAP (WHERE PERMITTED) 

The Pilot Terms contained a $100 AUD liability cap tied to the free pilot. Now that Raffy offers paid subscriptions, where liability can be limited by law our total liability to you for all claims arising in any 12-month period shall not exceed the greater of:

• $100 AUD, or

• The total subscription fees you paid to us in the 12 months immediately preceding the claim.

This cap does not apply to claims arising under the non-excludable consumer guarantees described above, or to our liability for death, personal injury, or fraud.

9.6 YOU MUST MITIGATE LOSS

You agree to take reasonable steps to minimise any loss, including maintaining independent records, exporting your data regularly, and reporting technical issues promptly.

9.7 UNFAIR CONTRACT TERMS

These Terms are a standard form consumer contract subject to the unfair contract terms regime under Part 2-3 of the ACL (as amended November 2023). We have drafted these Terms to comply with that regime. If a court determines that any term is unfair and therefore void, the remainder of the Terms continues in full force.

10. Ending Your Access

10.1 YOU CAN STOP ANYTIME

You may stop using Raffy and delete your account at any time with no questions asked:

• In-app: Settings → Account → Delete Account

• Email: raffy@raffyallergy.com with "Delete My Account" in the subject line

10.2 DATA EXPORT BEFORE DELETION

We will give you a minimum of 14 days to export your data before your account is permanently deleted. Export is available in PDF format from Stats → Export Data. This window can be extended on request.

10.3 WHAT HAPPENS AFTER DELETION

• Identifiable personal data will be deleted within 90 days of account closure

• De-identified, aggregated data already incorporated into research or analytics may be retained

• Some account data may be retained for legal compliance purposes for up to 7 years

• Deletion is permanent and cannot be reversed

10.4 SUSPENSION OR TERMINATION BY US

We may suspend or terminate your access if:

• You materially breach these Terms and do not remedy the breach within 7 days of notice

• You use Raffy in a way that poses a risk to others or to the integrity of the service

• Required by law or court order

Where suspension or termination is not caused by your breach (e.g. we discontinue the service), we will give you at least 30 days' written notice, provide a data export window, and issue a pro-rata refund of any prepaid subscription fees. This right cannot be waived.

10.5 EFFECT OF TERMINATION

On termination: your licence to use Raffy ends; you must stop using the App; clauses that by their nature survive termination (including Sections 2, 8, 9, 11, and 12) continue to apply.

11. General Terms

11.1 CHANGES TO THESE TERMS

We may modify these Terms from time to time. We will notify you by email and in-app notification. 

For material changes:

• We will give you at least 7 days' notice before the change takes effect

• We will clearly describe what is changing and why

• If the material change is not acceptable to you, you may cancel your account (and receive a pro-rata refund of prepaid fees) before the change takes effect, without penalty

For non-material changes (clarifications, corrections, updates to contact details), continued use after posting constitutes acceptance.

11.2 CHANGES TO RAFFY'S FEATURES

We may add, modify, or remove features. For changes that materially affect a feature you rely on as a paid subscriber, we will give you reasonable notice and if the change constitutes a major failure of a consumer guarantee,  the remedies described in Section 9.4 apply.

11.3 GOVERNING LAW AND JURISDICTION

These Terms are governed by the laws of Victoria, Australia. Disputes are subject to the non-exclusive jurisdiction of Victorian courts. Nothing in this clause limits your rights under the ACL or other applicable Australian law.

11.4 SEVERABILITY

If any provision is found invalid or unenforceable, it is severed to the minimum extent necessary, and the remaining provisions continue in full force.

11.5 NO WAIVER

Our failure to exercise or enforce any right does not constitute a waiver of that right.

11.6 FORCE MAJEURE

We are not liable for service interruptions caused by circumstances genuinely beyond our reasonable control (natural disasters, widespread internet failures, cyber attacks on critical infrastructure, government actions). This clause does not affect your rights under the ACL consumer guarantees in respect of any such interruption, nor does it excuse us from reasonable business continuity obligations.

11.7 ENTIRE AGREEMENT

These Terms and our Privacy Policy (April 2026) constitute the entire agreement between you and Raffy Pty Ltd regarding the App. They supersede the Pilot 1.0 Terms of Use (December 2025).

11.8 CONTACT DETAILS

PURPOSE

CONTACT

General enquiries

raffy@raffyallergy.com

Privacy Officer

raffy@raffyallergy.com

Account deletion

raffy@raffyallergy.com — subject: "Delete My Account"

Complaints

raffy@raffyallergy.com — subject: "Complaint"

Post

Raffy Pty Ltd, [Address], [State], Australia

12. Privacy 

The collection, use, disclosure, and management of your personal information (including sensitive health information about your child) is governed by our Privacy Policy (Version 1.0, April 2026), available at raffyallergy.com/privacy and in-app under Settings → Privacy Policy. The Privacy Policy forms part of the agreement between us.

12.1 KEY PRINCIPLES (SUMMARY)

• Health data: OIT logs, dose records, and reaction notes are stored locally

• No sale of your data. We will never sell your personal or health information.

• No advertising use. Your data is never used to target advertising to you.

• De-identified research only. Only fully de-identified, aggregated data may be used for research or product improvement. You may opt out: email raffy@raffyallergy.com with subject "Opt Out of Research".

• Your rights. You have the right to access, correct, and delete your data under the Privacy Act 1988 (Cth). See the Privacy Policy for how to exercise these rights.

• Breach notification. If a data breach likely to cause serious harm occurs, we will notify you and the OAIC as required by the Notifiable Data Breaches scheme.

12.2 SUB-PROCESSORS

We use third-party service providers (cloud hosting, authentication, analytics) who are contractually bound to protect your data. A current list of sub-processor categories is maintained in the Privacy Policy. Your health data is not shared with any sub-processor.

12.3 CHILDREN'S DATA

Accounts are held by parents or guardians (18+) who consent on behalf of their child. We do not allow children to create accounts independently. See Privacy Policy Section 10 for full details.

13. Complaints and Disputes

13.1 INTERNAL COMPLAINTS PROCESS

STEP

ACTION

TIMEFRAME

1. Contact us

Email raffy@raffyallergy.com with details of your complaint

—

2. Acknowledgement

We will acknowledge receipt

2 business days

3. Investigation and response

We will investigate and provide a substantive response

20 business days

4. Resolution or escalation

If unresolved, we will advise available escalation pathways

13.2 EXTERNAL ESCALATION

If we cannot resolve your complaint, you may escalate to:

• Privacy complaints: Office of the Australian Information Commissioner (OAIC) — 1300 363 992 · www.oaic.gov.au

• Consumer issues: Consumer Affairs Victoria — 1300 558 181 · www.consumer.vic.gov.au

• General consumer law (national): Australian Competition and Consumer Commission (ACCC) — 1300 302 502 · www.accc.gov.au

13.3 STATUTORY PRIVACY TORT

Under the Privacy and Other Legislation Amendment Act 2024 (in force June 2025), individuals may also bring court proceedings for serious invasions of privacy, independent of the OAIC complaint pathway.

13.4 NO RETALIATION

You will not be penalised for making a complaint in good faith. Your access to Raffy will not be affected by lodging a complaint.

14. Acknowledgment and Consent

By creating an account or using Raffy, you confirm that you have read, understood, and agree to these Terms in their entirety, including:

• I have read and understood these Terms of Use (Beta v2.0, April 2026)

• I understand Raffy is not a medical service, medical device, or source of medical advice

• I understand Raffy is in Beta and may have bugs, errors, or service interruptions

• I will consult my child's healthcare providers for all medical decisions

• I will call 000 in emergencies and will not rely on Raffy for emergency response

• I will maintain independent records of my child's protocol, doses, and reactions

• I have read and agree to the Privacy Policy (April 2026) and understand how my data is collected, used, and protected

• I consent to de-identified, aggregated data being used for research and product improvement (I may opt out at any time)

• I am at least 18 years of age with legal authority to consent on behalf of my child

• I understand that subscription pricing may change with 30 days' notice and that I may cancel before any price increase takes effect

• I understand I may end my account at any time without penalty and export my data before deletion

🚨 EMERGENCY QUICK REFERENCE

Always call 000 for: difficulty breathing · throat tightness · significant swelling (face, lips, tongue, throat) · persistent vomiting or severe abdominal pain · dizziness, confusion, or loss of consciousness · pale or blue skin · any symptom that severely concerns you.

Raffy IS for:

✓ Tracking doses and timing

✓ Logging reactions and cofactors

✓ Identifying patterns over time

✓ Generating clinician export reports

✓ General food allergy education

Raffy is NOT:

✗ Medical advice or diagnosis

✗ An emergency response tool

✗ A healthcare provider

✗ A regulated medical device

✗ A substitute for your allergist

Last Updated: December 2025
Version: 2.0

Questions? Contact raffy@raffyallergy.com